Legal Opinion

Figures v. Comm'r

United States Tax Court

Decided October 23, 2012No. Docket No. 9049-11Unpublished

R determined tax deficiencies and accuracy-related penalties pursuant to I.R.C. sec. 6662(a) for P's 2007, 2008, and 2009 taxable years.

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R determined tax deficiencies and accuracy-related penalties pursuant to I.R.C. sec. 6662(a) for P's 2007, 2008, and 2009 taxable years. R disallowed P's fictitious business losses and unsubstantiated gambling losses for all taxable years at issue, adjusted P's business income for 2009, disallowed a deduction for taxes for 2009, and disallowed the American opportunity credit P claimed for 2009. At trial P conceded the disallowance of the business losses and the adjustment to business income, leaving only the disallowance of gambling loss deductions for all years, deductions for taxes, the…

1Opinion of the Court

LAKEISHA RENEE FIGURES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Figures v. Comm'r

Docket No. 9049-11.

United States Tax Court

T.C. Memo 2012-296; 2012 Tax Ct. Memo LEXIS 297; 104 T.C.M. (CCH) 484;

October 23, 2012, Filed

Decision will be entered under Rule 155.

R determined tax deficiencies and accuracy-related penalties pursuant to I.R.C. sec. 6662(a) for P's 2007, 2008, and 2009 taxable years. R disallowed P's fictitious business losses and unsubstantiated gambling losses for all taxable years at issue, adjusted P's business income for 2009, disallowed a deduction for taxes for…

2Cases cited18 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Freytag v. CommissionerSupreme Court of the United States · 1991
  3. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  4. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  5. Vanicek v. CommissionerUnited States Tax Court · 1985

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